Offset Project Consistency Application Instructions

Reduction in Emissions of SF6

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Contents 1. 2. 3. Overview .............................................................................................................................. 3 Submission Instructions ....................................................................................................... 4 Consistency Application Forms ............................................................................................ 4 Part 1. General Information Forms ...................................................................................... 5 Part 2. Category-Specific Information and Documentation Forms ...................................... 7 Part 3. Independent Verification Form ............................................................................... 18

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1.

Overview

To demonstrate that an offset project involving reduction in emissions of SF6 qualifies for the award of CO2 offset allowances, a Project Sponsor must submit to the New York State Department of Environmental Conservation (Department), in accordance with these instructions, a Consistency Application Reduction in Emissions of SF6, (Consistency Application), including the coversheet and all forms and related attachments. The Project Sponsors inability to fully complete the Consistency Application forms pertaining to the accredited independent verifier information will not, in and of itself, disqualify such Project Sponsor from receiving an award of CO2 offset allowances, provided that the Consistency Application is submitted to the Department by the applicable deadline. Following these instructions will ensure that the Consistency Application contains all necessary information and is submitted properly. Each Project Sponsor should review the CO2 Budget Trading Program regulations at 6 NYCRR Subpart 242-10, addressing offset projects and the award of CO2 offset allowances. In making decisions regarding offset project eligibility, consistency determinations, and the award of CO2 offset allowances to project sponsors, the Department bases all review and determinations on the provisions of 6 NYCRR Subpart 242-10. Project sponsors should consider any project specifications, numerical thresholds, or similar standards contained in these instructions to be informal guidelines only, and not absolute requirements for the ultimate award of CO2 offset allowances. Before the Consistency Application can be completed, the Project Sponsor must establish a general account and obtain an offset project ID code through the Regional Greenhouse Gas Initiative (RGGI) CO2 Allowance Tracking System (RGGI COATS). The Project Sponsor identified in the Consistency Application must be the same as the Authorized Account Representative for the RGGI COATS general account identified in the Consistency Application. For information about establishing a RGGI COATS general account and offset project ID code, consult the RGGI COATS Users Guide, available at http://www.rggi-coats.org. Key eligibility dates and application submittal requirements for offset projects are as follows: For offset projects commenced between December 20, 2005, and December 31, 2008, the Consistency Application must be submitted by June 30, 2009. For offset projects commenced on or after January 1, 2009, the Consistency Application must be submitted within six months after the project is commenced. For an offset project located in New York, the Consistency Application must be filed with the Department. For an offset project located in more than one participating state, the Consistency Application must be filed in the participating state where the majority of the CO2equivalent emissions reduction or carbon sequestration due to the offset project is expected to occur.

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2.

Submission Instructions

Submit one (1) hardcopy original Consistency Application as well as an electronic copy in the form of a CD to the Department at the location specified below. Submit hardcopies of forms requiring signatures as originally-signed copies and scan such signed forms for electronic submission. Facsimiles of the Consistency Application are not acceptable under any circumstances. New York State Department of Environmental Conservation Office of Climate Change 625 Broadway Albany, New York 12233-1030 Attn: John Marschilok The Consistency Application has three parts, as described below. Each part comprises specified forms and required documentation. Enter information directly into the fields provided or submit information or documentation as an attachment, as directed. Include headers on all attachments indicating the form to which each is attached, the offset project name, and offset project ID code. The Project Sponsor should save an electronic copy for his or her file to serve as a reference for any necessary remediation.

3.

Consistency Application Forms

The Consistency Application includes ten (10) forms divided into three parts, as follows: Part 1. General Information Forms Form CA-1.1B Coversheet Form CA-1.2B General Information Form CA-1.3B Attestations Form CA-1.4B Project Sponsor Agreement Form CA-1.5B Disclosure of Greenhouse Gas Emissions Data Reporting

Part 2. Category-Specific Information and Documentation Forms Form CA-2.1B Project Description Form CA-2.2B Demonstration of Eligibility Form CA-2.3B Emissions Baseline Form CA-2.4B Monitoring and Verification Plan

Part 3. Independent Verification Form Form CA-3.1B Independent Verifier Certification Statement and Report

The following instructions address each of the forms in numerical order. Note that the forms themselves include many embedded instructions.

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Part 1. General Information Forms

The five (5) forms in Part 1 of the Consistency Application address general requirements applicable to SF6 offset projects. Instructions for the Part 1 forms are provided below.

Form CA-1.1B

Coversheet

Enter the requested information in the editable text fields in the form. Check the boxes to indicate which forms are being submitted. For information about entering the Project Sponsor, offset project name and offset project ID code, and RGGI COATS account name and number, see instructions below for Form CA-1.2B, General Information. Submit all forms including the Coversheet. If a required form is not submitted, the Consistency Application will not be considered complete for commencement of review by the Department.

Form CA-1.2B

General Information

Enter the requested information in the editable text fields in the form. If a text field is not applicable or is unanswerable, enter NA. Note the following: Offset Project ID Code: Enter the offset project ID code. The offset project ID code is the alphanumeric code generated when the Project Sponsor creates a record of the offset project in RGGI COATS. See the RGGI COATS Users Guide for more information about creating an offset project record in RGGI COATS, available at http://www.rggi-coats.org. Project Information: Enter project information. The name of the offset project should be the same name entered by the Project Sponsor when creating a project record in RGGI COATS. The project location entered should be the primary location of the project if the project consists of actions at multiple locations. The summary narrative of the project should indicate all locations where project actions occur or will occur. Project Sponsor: Identify the Project Sponsor and provide his or her contact information. The Project Sponsor is the natural person who is the Authorized Account Representative for the RGGI COATS general account identified in the Consistency Application. Project Sponsor Organization: Provide the full legal name of the organization that the Project Sponsor represents, including any alternative names under which the organization also may be doing business (e.g., John Doe Enterprises, Inc., d/b/a JDE). If the Project Sponsor is representing himself or herself as an individual, enter NA. RGGI COATS General Account Name and Number: Enter the RGGI COATS general account name and number. The RGGI COATS general account

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identified in the Consistency Application is the RGGI COATS account into which any awarded CO2 offset allowances related to the offset project will be transferred.

Form CA-1.3B

Attestations

Sign and date the form. Submit the originally signed form as part of the paper hardcopy Consistency Application. Scan the signed, notarized, and dated form for submission as part of the electronic version of the Consistency Application.

Form CA-1.4B

Project Sponsor Agreement

Sign and date the form. Submit the originally signed form as part of the paper hardcopy Consistency Application. Scan the signed, notarized, and dated form for submission as part of the electronic version of the Consistency Application.

Form CA-1.5B

Disclosure of Greenhouse Gas Emissions Data Reporting

Check the appropriate box in the form to indicate whether greenhouse gas emissions data related to the offset project have been or will be reported to any voluntary or mandatory programs, other than the New York CO2 Budget Trading Program. For each program for which data have been or will be reported, provide the program name, the program type (voluntary or mandatory), program contact information (website or street address), the categories of emissions data reported, the frequency of reporting, when the reporting began or will begin, and reporting status (prior, current, future). The Project Sponsor must disclose future reporting related to current commitments made to voluntary programs as well as future reporting mandated by current statutes, regulations, or judicial or administrative orders.

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Part 2. Category-Specific Information and Documentation Forms

The four (4) forms in Part 2 of the Consistency Application address category-specific requirements and documentation applicable to SF6 offset projects. Instructions for the Part 2 forms are provided below.

Form CA-2.1B

Project Description

Attach a detailed narrative of the offset project. The attached narrative must include a header that indicates it is an attachment to Form CA-2.1B and identifies the offset project name and offset project ID code. The narrative must include the following information: 1. Description of Entity and Service Territory. Describe the transmission and/or distribution entity. List and describe the assets and equipment used to transmit and distribute electricity to the electrical load of customers within the entity. All of the assets and equipment listed as part of the transmission and/or distribution entity must be located within New York. The geographic area of the transmission and/or distribution entity may not span more than one state. Describe the service territory of the electric transmission and/or distribution entity. List all geographic locations (e.g., counties, cities, towns) that the entity serves. Include a map to scale of the service territory representing authorized areas of service. The service territory described must be that specified by the Public Service Commission for which the entity has a regulatory obligation to serve electrical load. 2. Owner and Operator of Entity. Provide the organization legal name(s), point(s) of contact information, and physical address for both the owner and operator of the transmission and/or distribution entity. Provide the same owner and operator names and contact information as provided to the Public Service Commission. The owner is the legal entity that owns the transmission and/or distribution entity. The operator, which may or may not be identical to the owner, is the legal entity responsible for operating, controlling, or supervising the transmission and/or distribution entity under a written contract with the owner of entity. If the owner or operator of the transmission and/or distribution entity is a subsidiary of a corporate parent or holding company, provide the organization legal name(s), point(s) of contact information, and physical address for the parent company. 3. Description of Incremental Actions and Summary of Eligibility. Describe the incremental actions that will be taken as part of the offset project in one or more of the following three categories: (1) early retirement and replacement of electrical equipment; (2) repair/refurbishment of electrical equipment, including specific management practices to reduce equipment leakage of SF6; and (3) education and training to improve handling of SF6, including cylinder handling and gas cart operation and maintenance. Describe how such actions are consistent with the guidance provided in International Electrotechnical Commission (IEC) 1634, Highvoltage switchgear and control gearUse and handling of SF6 in high-voltage switchgear and control gear (CEI/IEC 1634, 1995-04), and Electric Power Research Institute (EPRI), Practical Guide to SF6 Handling Practices (TR-113933,

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2002). All incremental actions must take place within the boundaries of the transmission and/or distribution entity. Summarize the documentation provided in Form CA-2.2B that demonstrates that the offset project meets the eligibility requirements of 6 NYCRR Paragraph 24210.5(b)(1).

Form CA-2.2B

Demonstration of Eligibility

Enter the requested information directly in the editable text fields in Form CA-2.2B and attach documentation, as directed below. Each attachment must include a header that indicates it is an attachment to Form CA-2.2B and includes the offset project name and offset project ID code. The following information and documentation must be provided: 1. Calculate and enter the baseline year SF6 emissions rate for the transmission and/or distribution entity where indicated on the form. Based on 6 NYCRR Subdivision 242-10.5(b), Table 1, enter the applicable emissions rate performance standard that applies to the entity where indicated on the form. To demonstrate that the offset project has an SF6 entity-wide emissions rate for the baseline year that is less than the applicable emissions rate performance standard, calculate the emission rate using the following formula: SF6 Emissions Rate (%) = [(Total SF6 Emissions for Baseline Year)/ (Total SF6 Nameplate Capacity at End of Baseline Year)] x 100 The entity-wide emissions used to calculate the entity-wide emissions rate entered in Form 2.2 must be that provided in Form CA-2.3B to document baseline year SF6 emissions for the transmission and/or distribution entity. Total SF6 nameplate capacity at the end of the baseline year must be that provided in the Entity-wide SF6 Inventory Tracking System as an attachment to Form CA-2.3B. If the entity-wide emissions rate is less than the applicable emissions rate performance standard, then Form CA-2.2B is complete. 2. If the SF6 emissions rate is greater than the applicable emissions rate performance standard, attach documentation to demonstrate that the project is being implemented at a transmission and/or distribution entity serving a predominantly urban service territory and that at least two of the four criteria listed at b. through e. below are met: a. Predominantly Urban Service Territory. Provide documentation regarding: (1) the percentage of the entitys SF6 nameplate capacity that is located in an urban area; and/or (2) the percentage of the electrical load served within the entitys service territory that is located in an urban area. An urban area consists of an urbanized area (UA) or an urban cluster (UC). An urbanized area consists of core census block groups or blocks that have a population density of at least 1,000 people per square mile. An urban cluster consists of surrounding census blocks that have an overall density of at least 500 people per square mile. Include the following documentation (include (i) and either (ii) or (iii)): (i) Map to scale of the service territory delineating the specific geographic locations that have equal to or greater than 1,000 persons per square mile. For these geographic

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locations, list the names of the urban areas, their populations, and population densities; and (ii) Documentation regarding the percentage of the entitys SF6 nameplate capacity is located in urban areas. Identify the manufacturer and model of the equipment, total SF6 nameplate capacity, and equipment locations (e.g., name of substation) in urban areas. Total the nameplate capacity of SF6-containing operating equipment that is located in urban areas. Divide that total by the total SF6 nameplate capacity that was used to calculate the emissions rate; or (iii) Documentation regarding the percentage of the entitys electrical load served within its service territory is located in an urban area. If the documentation provided pursuant to (ii) or (iii) above results in a percentage greater than 50%, no further documentation is required. If the percentage result is 50% or less, provide additional narrative and documentation to demonstrate that the project is being implemented at a transmission and/or distribution entity serving a predominantly urban service territory. b. Age of Equipment: Provide documentation that the entity is comprised of transmission and distribution equipment that is older than the national average age of equipment. Identify the year of purchase or year of installation of each piece of installed transmission and distribution equipment that has an SF6 nameplate capacity. Divide the SF6 nameplate capacity of the equipment that is older than the national average age of transmission and distribution equipment (30 years) 1 by the total SF6 nameplate capacity used to calculate the baseline entity-wide emissions rate. If the result is greater than 75% of the total SF6 nameplate capacity, no further documentation is required. If the result is 75% or less of the total SF6 nameplate capacity, provide additional narrative and documentation to demonstrate that the entity is comprised of older than average installed transmission and distribution equipment in relation to the national average age of equipment. c. Poor Accessibility to Underground Equipment: Provide documentation that a majority of the entitys electricity load is served by equipment that is located underground. Identify the manufacturer and model of the SF6-containing operating equipment located underground, the SF6 nameplate capacity of such equipment, and the underground locations of each piece of such equipment. Divide the total SF6 nameplate capacity identified as being located underground by the total SF6 nameplate capacity used to calculate the baseline entity-wide emissions rate. Demonstrate that regular ongoing maintenance is precluded by the location of underground equipment. Describe how maintenance procedures, schedules, or costs differ for underground equipment compared to above-ground equipment in terms of the frequency, duration, cost, and/or other similar factors. If the result of the documentation listed above indicates that greater than 50% of the entitys total SF6 nameplate capacity is located underground, no further documentation is required. If the result is 50% or less, provide additional narrative and documentation to demonstrate that a majority of the entitys electricity load is served by equipment that is
The Department generally considers the national average age of equipment to be 30 years, and this figure should be used by project sponsors for this calculation. If the project sponsor believes that 30 years does not accurately reflect the national average, the project sponsor should provide additional narrative justifying the use of a different number for the national average.
1

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located underground, and poor accessibility of such underground equipment precludes management of SF6 emissions through regular ongoing maintenance. Retain supportive documentation for inspection by the Department and independent verifier, such as third-party audits, reports to regulators or other organizations responsible for system reliability, and written maintenance procedures, schedules, and/or other records. d. System Reliability: Provide documentation of the inability to take a substantial portion of equipment out of service, as such activity would impair system reliability. Identify the manufacturer, model, and SF6 nameplate capacity of each piece of SF6-containing operating equipment in the entitys service territory that, if taken out of service, would impair system reliability. Total the SF nameplate capacity of this equipment. Divide that total by the total SF6 nameplate capacity used to calculate the baseline entity-wide emissions rate. If the result is greater than 33% of the total SF6 nameplate capacity, no further documentation is required. If the result is 33% or less, provide additional narrative and documentation to demonstrate the inability to take a substantial portion of equipment out of service, as such activity would impair system reliability. Retain supportive documentation for inspection by the Department and independent verifier, such as third-party audits, reports to regulators or other organizations responsible for system reliability, written equipment replacement procedures and schedules, and/or other records that substantiate that the SF6-containing operating equipment cannot be taken out of service without impairing system reliability. Include as part of such supportive documentation entity-wide decommissioning records for the previous two years showing that similar equipment has not been taken out of service. An example of relevant data would be evidence that the entity or a subset of the entity has a load factor of at least 80%, resulting in insufficient capacity to cover the circuit outages resulting from equipment taken out of service. e. Inherently Leak-Prone Equipment: Provide documentation that required equipment purpose or design for a substantial portion of entity equipment results in inherently leakprone equipment. Identify the manufacturer, model, and SF6 nameplate capacity of each piece of equipment that has a required purpose or design that result in it being inherently leak-prone. Inherently leak prone equipment is generally considered to be SF6-containing operating equipment with an average annual SF6 leak rate of 10% or higher since its installation. If actual equipment leak data are unavailable, estimate the average annual leak rates for individual pieces of equipment based on the number of service calls required since the equipments installation and the amount of SF6 leakage that typically triggers a service call (e.g. 10% loss of nameplate capacity). For example, a piece of equipment in service for three years that has required six service calls since its installation meets the definition of inherently leak-prone since its implied average annual leak rate of 20% (two service calls per year and assumed 10% loss of nameplate capacity per service call) is greater than the average annual leak rate of 10%. Total the SF6 nameplate capacity of the inherently leak-prone equipment. Divide that total by the total SF6 nameplate capacity used to calculate the baseline entity-wide emissions rate. If the result is greater than 33% of the nameplate capacity of SF6containing operating equipment, no further documentation is required.

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If the result is 33% or less of the total SF6 nameplate capacity, provide additional narrative and documentation to demonstrate that required equipment purpose or design for a substantial portion of entity transmission and distribution equipment results in inherently leak-prone equipment. Retain supportive documentation for inspection by the Department and independent verifier, such as third-party audits, manufacturer or industry studies, reports to regulators or other organizations responsible for system reliability, or written equipment replacement data and schedules.

Form CA-2.3B

Emissions Baseline

Provide the following information in the editable text fields in Form CA-2.3B or as an attachment, as directed. Each attachment must include a header that indicates it is an attachment to Form CA-2.3B and includes the offset project name and offset project ID code. The following information and documentation must be provided as specified below: 1. Identify Baseline Year. Enter the designated baseline year where requested in Form CA-2.3B. The baseline year must be the calendar year immediately proceeding the calendar year in which the Consistency Application is filed. Enter SF6 Values from the Entity-wide SF6 Inventory Tracking System. Enter the requested SF6 values in Form CA-2.3B. The SF6 values must be derived from the submitted Entity-wide SF6 Inventory Tracking System (see instructions at Number 3 below). To calculate the total entity-wide emissions of SF6 for the baseline year, use the following mass-balance method: SF6 Emissions (lbs) = (SF6 Change in Inventory) + (SF6 Purchases and Acquisitions) (SF6 Sales and Disbursements) (Change in Total SF6 Nameplate Capacity of Equipment) To calculate the SF6 values requested, use the following equation that corresponds to the mass balance method described above:
SF6 Change in Inventory (lbs) = (Viby Viey) + Purchases and Acquisitions of SF6 (lbs) (PApsd + PAe + PArre) Sales and Disbursements of SF6 (lbs) (SDop + SDrs + SDdf + SDsor) Change in Total SF6 Nameplate Capacity of Equipment (lbs) (CNPne CNPrse)

2.

Total SF6 Emissions (lbs)

where: SF6 Change in Inventory is the difference between the quantity of SF6 gas in storage at the beginning of the reporting year (i.e., Viby) and the quantity in storage at the end of the reporting year (i.e., Viey). The term quantity in storage includes all SF6 gas contained in cylinders (such as 115-pound storage cylinders), gas carts, and other storage containers. Quantity in storage does not include SF6 gas contained in SF6-using operating equipment. The change in

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storage inventory will be negative if the quantity of SF6 gas in storage increases over the course of the year. This portion of the equation is defined as follows: Viby = SF6 inventory in cylinders, gas carts, and other storage containers (not SF6-containing operating equipment) at the beginning of the reporting year 2 Viey = SF6 inventory in cylinders, gas carts, and other storage containers (not SF6-containing operating equipment) at the end of the reporting year

Determine change in inventory based on the quantities of SF6 gas contained in each cylinder, storage container, and gas cart at both the start of the year and the end of the year. Total the start and end quantities for cylinders, as recorded in cylinder logs required by the SF6 Inventory Management and Auditing Protocol (see instructions for Form CA-2.4B). Total the start and end quantities for gas carts and any other storage containers, as recorded in the Entity-wide SF6 Inventory Tracking System. Combine totals to obtain the storage inventory total. Use quantities that represent the physical weights of the gas stored, not a calculated estimate based on temperature and pressure. Purchases and Acquisitions of SF6 are the sum of all the SF6 gas acquired from other parties during the reporting year, contained in storage containers or SF6using operating equipment. Acquisitions include SF6 provided by equipment manufacturers with and inside equipment and SF6 returned to the entity after offsite recycling. This portion of the equation is defined as follows: PApsd = SF6 purchased from suppliers or distributors in cylinders PAe = SF6 provided by equipment manufacturers with or inside SF6containing operating equipment PArre = SF6 returned to the reporting entity after off-site recycling

Sum the additions to the inventory during the year. Log each purchase and acquisition into the Entity-wide SF6 Inventory Tracking System. Retain as documentation of data, for inspection by the Department and independent verifier, the corresponding purchase/acquisition records of SF6 gas and SF6 gas that accompanies SF6-containing equipment purchases, supplier receipts of cylinders, and receipts of recycled SF6 returned to the entity after off-site recycling. Sales and Disbursements of SF6 are the sum of all the SF6 gas sold or otherwise disbursed to other parties during the reporting year, contained in storage containers and SF6-using operating equipment. Disbursements include SF6 returned to the supplier, SF6 sent off-site for recycling, and SF6 sent off-site for destruction. This portion of the equation is defined as follows:

The beginning-of-year inventory for a given year should always equal the end-of-year inventory for the previous year. Therefore, an end-of-year inventory measurement should be applied to the beginningof-year inventory input for the following calendar year.

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SDop = Sales of SF6 to other parties, including gas left in SF6-containing operating equipment that is sold SDrs = Returns of SF6 to supplier (producer or distributor) SDdf = SF6 sent to destruction facilities SDsor = SF6 sent off-site for recycling

Sum the subtractions from inventory, i.e., the sales and disbursements of SF6 during the reporting year. Log each sale and disbursement into the Entity-wide SF6 Inventory Tracking System. Retain as documentation of data, for inspection by the Department and independent verifier, the corresponding sales/disbursement records of SF6 gas and SF6 gas that is contained within equipment sold, supplier receipts of cylinders, and receipts of SF6 sent to destruction facilities or off-site for recycling. Change in Total SF6 Nameplate Capacity of Equipment is the net change in total nameplate capacity of SF6-containing operating equipment during the reporting year. The net change in nameplate capacity is equal to new equipment nameplate capacity minus retired equipment nameplate capacity. This quantity will be negative if the retired equipment has a total nameplate capacity larger than the total nameplate capacity of the new equipment. Nameplate capacity refers to the full and proper SF6 charge of the equipment rather than to the actual charge, which may reflect leakage. This portion of the equation is defined as follows: CNPne = Total SF6 nameplate capacity of new SF6-containing operating equipment at proper full charge CNPrse = Total SF6 nameplate capacity of retired SF6-containing operating equipment at proper full charge

Record the total SF6 nameplate capacity of equipment at both the start of the reporting year and the end of the reporting year in the Entity-wide SF6 Inventory Tracking System. Determine change in total SF6 nameplate capacity of equipment based on the difference between the two quantities. Retain as documentation of data, for inspection by the Department and independent verifier, records of newly installed equipment and records of retired equipment. 3. Provide Inventory Documentation. Attach the Entity-wide SF6 Inventory Tracking System to Form CA-2.3B as documentation of reported SF6 values and emissions calculations. This is the entity-wide tracking system specified in the Monitoring and Verification Plan (see instructions for Form CA-2.4B). The attached inventory tracking system must be provided in spreadsheet form (or other appropriate database form) and include a header that indicates it is an attachment to Form CA2.3B and includes the offset project name and offset project ID code. For submission of the electronic version of the Consistency Application, provide the spreadsheet as a distinct electronic file.

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Form CA-2.4B

Monitoring and Verification Plan

Provide the Monitoring and Verification (M&V) Plan as an attachment to Form CA-2.4B. The attached M&V Plan, and any related separate attachments, must include a header that indicates it is an attachment to Form CA-2.4B and includes the offset project name and offset project ID code. Check the boxes in Form CA-2.4B to indicate that the attached M&V Plan includes the required components. The M&V Plan must include the following: 1. Data Sources and Calculations. Document the data sources and calculations that will be used to determine baseline year SF6 emissions and reporting year SF6 emissions. Data sources and calculations must be consistent with those required pursuant to 6 NYCRR Subdivision 242-10.5(b). SF6 Inventory Management and Auditing Protocol. Provide an SF6 Inventory Management and Auditing Protocol, which must include the following: a. Description of the Entity-wide SF6 Inventory Tracking System. Provide a detailed description of the Entity-wide SF6 Inventory Tracking System, including system maintenance, system back-up, system security features, report capacities, and a list of data fields. Provide a spreadsheet template (or other appropriate database template) of the Entity-wide SF6 Inventory Tracking System, which must contain the following: i. ii. iii. Identification of the facility(ies) from which all SF6 gas is procured and disbursed; An entity-wide log of all SF6 gas procurements and disbursals; and An entity-wide inventory of all SF6-containing operating equipment and all other SF6--related items, including cylinders, gas carts, and other SF6 storage containers.

2.

b. Personnel Contact Information. Provide the following information for personnel responsible for maintaining the Entity-wide SF6 Inventory Tracking System: i. An organizational structure of the inventory management team, which identifies the names and contact information for the personnel selected to oversee data entry into the Entity-wide SF6 Inventory Tracking System and into any distinct tracking system for a substation(s) or other designated location(s) that is used to provide data to the Entity-wide SF6 Inventory Tracking System (include names of outside contractors that provide inventory management and/or data entry services); and Names and contact information of the auditors of the Entity-wide SF6 Inventory Tracking System and any distinct tracking system(s) for a substation(s) or other designated location(s) that is used to provide data to the Entity-wide SF6 Inventory Tracking System.

ii.

c. Inventory Tracking System Procedures and Training. Document the following Entity-wide SF6 Inventory Tracking System procedures for data input, records keeping and records retention, and maintenance of cylinder logs:

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i.

Procedures for input of data into the Entity-wide SF6 Inventory Tracking System and any other distinct tracking system for a substation(s) or other designated location(s) that is used to provide data to the Entity-wide SF6 Inventory Tracking System (e.g., data entry frequency; data fields requirements); Procedures for records retention, including: purchase/sales records, supplier receipts of cylinders received from and returned to the supplier, recycling and destruction receipts, and records of newly installed SF6containing operating equipment and retired equipment; Procedures for the maintenance of cylinder-specific logs, including maintenance of a master sheet identifying all cylinders using unique identifiers, and a standardized cylinder log form that includes: (A) (B) Location and specific identifying information of the equipment being filled with the SF6 gas from the cylinder; Location and specific identifying information of the equipment from which SF6 is being recovered and placed into the cylinder for transfer, reuse, recycling, reclamation, or destruction purposes; and Weight of the cylinder before and after: (1) the cylinder is connected to and disconnected from an automated gas top-off and filling system; or (2) any activity where gas is manually added to or removed from a cylinder. Note that estimating the weight of a cylinder using temperature and pressure to estimate SF6 disbursed from or added to a cylinder is permitted for interim measurements of cylinder weight throughout the year. However, estimating cylinder weight using temperature and pressure is not allowed for determining beginning-ofyear and end-of-year cylinder weight. Physical weighing of cylinders using a certified scale is the only acceptable method for calculating cylinder weight that will be used to determine inputs to the massbalance formula; 3 and

ii.

iii.

(C)

iv.

Procedures for confirming that meters and scales are used for the filling and weighing of cylinders at each substation or other location designated for such activities and are consistently calibrated to manufacturer recommendations; and An entity-wide training plan for the inventory management team on the use of the Entity-wide SF6 Inventory Tracking System as a data source, the use of the SF6 mass-balance method, and recordkeeping and record retention practices.

v.

d. Auditing Procedures and Plans. Document the following auditing procedures and plans: i. A schedule (i.e., calendar of dates) for conducting audits;

Temperature and pressure based calculations are not considered reliable enough for determining inputs that will be used to calculate emissions. Temperature and pressure based calculations are limited by the gas law scope of their application.

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ii.

Procedures for audits of inventory management, including all inventory tracking systems, data entry, and maintenance of cylinder logs in accordance with the M&V Plan; A template for a report on the findings of audits including identification of areas in need of corrective actions; and An entity-wide training plan for auditors on how to conduct the procedures for the audits.

iii. iv.

3.

Quality Assurance/Quality Control (QA/QC) Protocol. Document the QA/QC process, which must include the following: a. Contact Information and QA/QC Schedule. Provide the following: i. ii. Names and contact information for QA/QC officers in charge of administering the QA/QC process for inventory data; and A schedule establishing periodic (such as quarterly or semi-annually) QA/QC procedures for the inventory of: (A) (B) Entity-wide SF6 gas procurements and disbursals; All SF6-containing operating equipment and all other SF6 storagerelated items, including cylinders, gas carts, and other SF6 storage containers; and All cylinder logs; and

(C)

b. QA/QC Procedures and Training. Document the following QA/QC procedures and training plan: i. Procedures for entity-wide inventory of SF6 gas procurements and disbursals, which include a review of at least 10% of the receipts for purchases/sales and disbursals kept at each substation (or other designated location) against entries in the Entity-wide SF6 Inventory Tracking System to ensure accuracy and completeness in data entry; Procedures for entity-wide inventory of all operating equipment containing SF6, which include a review of at least 10% of the records of newly installed and retired equipment and corresponding SF6 nameplate capacity against entries in the Entity-wide SF6 Inventory Tracking System to ensure accuracy and completeness in data entry; Procedures for all cylinder logs, which include: (A) Confirmation in the form of certifications signed by inventory management team members that meters and scales are consistently calibrated to manufacturer recommendations for the filling and weighing of cylinders at each substation (or other designated location); and Periodic review of the master sheet of cylinder logs to account for cylinder totals at each substation (or other designated location); and

ii.

iii.

(B) iv.

Procedures for the review of annual emissions calculations in order to:

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(A)

Ensure complete compilation of data from all designated personnel of the inventory management team into the Entity-wide SF6 Inventory Tracking System prior to calculation of emissions; Identify unusually large changes to inventory, purchases/acquisitions, or sales/disbursals, and determine if the changes can be explained or if there is an error in reported inputs to the SF6 mass balance method; and Ensure no negative inputs are entered and negative emissions are not calculated, except for changes in storage inventory and nameplate capacity, which may result in negative numbers; and

(B)

(C)

v.

An entity-wide training plan for QA/QC officers addressing QA/QC procedures for Entity-wide SF6 Inventory Tracking System data entry, use of the SF6 mass-balance method, compilation and retention of associated sources of data, and recordkeeping practices to ensure consistent and complete inventory data.

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Part 3. Independent Verification Form

The form in Part 3 of the Consistency Application addresses requirements and documentation related to the independent verifier certification statement and report. Instructions for the form in Part 3 are provided below.

Form CA-3.1B

Independent Verifier Certification Statement and Report

An accredited verifier must sign and date the form. Submit the originally signed form as part of the paper hardcopy of the Consistency Application. Scan the signed and dated form for submission as part of the electronic version of the Consistency Application. The Project Sponsors inability to fully complete the Independent Verification Form will not, in and of itself, disqualify such Project Sponsor from receiving an award of CO2 offset allowances, provided that the Consistency Application is submitted to the Department by the applicable deadline. Provide the independent verifier report as an attachment to Form CA-3.1B. The verifier report must include a header that indicates it is an attachment to Form CA-3.1B and includes the offset project name and offset project ID code. The verifier report must document the following: 1. The verifier has reviewed the entire Consistency Application and evaluated the contents of the application in relation to the applicable requirements of 6 NYCRR Subpart 242-10. 2. The verifier has evaluated the adequacy and validity of information supplied by the Project Sponsor to demonstrate that the offset project meets the applicable eligibility requirements of 6 NYCRR Section 242-10.3 and 6 NYCRR Section 242-10.5. 3. The verifier has evaluated the adequacy and validity of information supplied by the Project Sponsor to demonstrate baseline emissions, pursuant to the applicable requirements of 6 NYCRR Subdivision 242-10.5(b). 4. The verifier has evaluated the adequacy of the monitoring and verification plan submitted pursuant to the applicable requirements of 6 NYCRR Section 242-10.5. The verifier report must include the following contents, in the order listed below: Cover page with report title and date Table of contents List of acronyms and abbreviations Executive summary Description of objective of report Identification of the client, including name, address, and other contact information Identification of the offset project Description of evaluation criteria (applicable regulatory provisions and documentation required in the Consistency Application)

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Description of the review and evaluation process, including any site visits and interviews Identification of individuals performing the verification work, including the verification team leader and key personnel, and contact information for the team leader Description of the materials provided to the verifier by the Project Sponsor Evaluation conclusions and findings, including level of assurance provided

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